REMEDIAL ACTION PLAN & SYSTEM DESIGN CHECKLIST Bureau [PDF]

REQUIREMENTS OF THE PRE-APPROVAL PROGRAM REMEDIAL ACTION INITIATIVE (RAI). For cleanup projects affected by the Pre-Appr

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REMEDIAL ACTION PLAN & SYSTEM DESIGN CHECKLIST

Bureau of Petroleum Storage Systems

Florida Department of Environmental Protection

Facility Name: ______________________________________________________________ Location: ______________________________________________________________ FAC ID No: ______________________________________________________________ Reviewer: ______________________________________

Contractor:

Preapproval Site:

[ ]

State Cleanup Site:

[ ]

Voluntary Cleanup Site:

[ ]

______________________

This checklist should not be applied in blanket fashion. Technical judgment may be necessary in determining the applicability of some items. However, all information listed that is relevant to the remedial design should be provided.

I. GENERAL _______

(1) RAP signed, sealed, and dated by Florida P.E. (per Section 471.025, FS)

_______

(2) indication whether proposed plan is for preapproval program, state contracted cleanup, or voluntary cleanup

_______

(3) recap of SAR information and conclusions pertinent to RAP preparation

_______

(4) current sampling results [within nine (9) months] used for remediation system design

_______

(5) potable water considerations: ♦ method of potable water supply to site and surrounding area ♦ locations of private wells within 1/4-mile, and public wells within 1/2-mile radius of site ♦ indication whether FDEP district office drinking water program was notified if contaminated groundwater could be expected to reach any public or private water well. Method of notification, person notified, and date

_______

(6) identification underground utilities locations, and those which may enhance transport of contaminants

_______

(7) h cleanup time:

_______

(8) fencing of treatment area required, unless public access is restricted by institutional controls

estimated cleanup time for the groundwater, for the soil

_______

(9)

local, state, and federal permits to be obtained, and conditions stated

_______

(10) recap of alternatives discussed and/or alternative selected during pre-RAP conference, or cost-effectiveness analysis of alternatives and identification of recommended alternative

_______

(11) statement that signed and sealed as-built (record) drawings will be provided

_______

(12) nuisance noise and odor to neighbors avoided by careful location of equipment items and exhaust stacks or other mitigating measures II. REQUIREMENTS OF THE PRE-APPROVAL PROGRAM REMEDIAL ACTION INITIATIVE (RAI)

For cleanup projects affected by the Pre-Approval Program Remedial Action Initiative, the requirements of this section apply. The items listed below in this section are to be taken into account for each of the operations covered by the other sections of this checklist. _______

(1) Cleanup Goals established. End of Active Remediation goal: 70% of natural attenuation default concentrations (NADC), or 90% reduction of each contaminant group, in each key well in the source area, whichever is more

RAP_Checklist_02-03-04.doc

REMEDIAL ACTION PLAN CHECKLIST

Page 2 FAC ID No:___________________________________________

stringent, in the specified time frame (typically one to four years). Longer cleanup times to achieve end of active remedial action goal require special justification. _______

(2) Pilot testing of the proposed remediation strategy is generally required. Exceptions require special justification.

_______

(3) Remediation equipment must meet the specifications contained in the Remedial Action Initiative including reasonable safety factors.

_______

(4) System designs includes adequate source area treatment wells, e.g. a safety factor of 2, and consideration of using parallel or zoned systems.

_______

(5) Ultimate cleanup target levels need to be indicated, either (CTLs) of Chapter 62-770 for unconditional NFA, or Alternative CTLs for conditional NFA. For conditional NFA, owner’s acknowledgement of future institutional controls at cleanup completion should be documented

_______

(6) End of Active Remediation to be followed by Natural Attenuation Monitoring. An evaluation of “time to switch” from active remedial action to Natural Attenuation Monitoring to reach ultimate cleanup target levels may be performed to allow for the continuation of active remedial action if justified.

_______

(7) Milestones schedule must be included in RAP using the BPSS milestone model. The schedule must identify key wells, contaminants of concern, baseline contaminant concentrations, and time to reach the end of active remedial action. A linear concentration vs. time profile shall apply to each contaminant group in each key well.

_______

(8) Applicability of “difficult sites” evaluation procedures established (mandatory if post-assessment cleanup cost will likely exceed $500,000 or cleanup time will exceed 4 years). Some elements of the “difficult sites” evaluation procedures may be applicable to sites with cleanups, which will not exceed $500,000, or a 4 year cleanup time. If applicability established, FDEP PE must complete difficult sites checklist attached to May 21, 2003 Difficult Sites memorandum.

_______

(9) RAP must include a Construction Plan and a construction schedule.

_______

(10) RAP must include a Startup Test Plan, and startup testing must be conducted in accordance with manufacturer’s recommendations.

_______

(11) RAP must include a Preventative and Routine Maintenance Plan and checklist, a Repair Response Plan and maintenance visit schedule. The repair response plan must address sytem monitoring, equipmant operation and replacement part availability and supply.

_______

(12) RAP must indicate that equipment will be UL approved (or equivalent) and will have a warranty

_______

(13) Hour meters, flow meters, pressure gauges, and vacuum gauges specified for all critical components, including individual wells if necessary for optimization of system efficiency

_______

(14) Autodialer system specified (telemetry may be specified with justification)

_______

(16) Equipment items must be protected (covered or housed in a trailer).

_______

(17) Specifications, and an Operations Manual must be provided to FDEP/LP, and a copy must be kept at the site.

_______

(18) RAP specifies that Startup, Quarterlyand Annual Reports will be provided, and must include the information detailed in the RAI. III. FREE PRODUCT REMOVAL

_______

(1) free product plume identification

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REMEDIAL ACTION PLAN CHECKLIST

Page 3 FAC ID No:___________________________________________

_______

(2) description/design details of free product recovery system including: ♦oil/water separator sizing calculations and detention time ♦ free product storage tank of adequate size

_______

(3) automated product pump shutdown for high level in product tank

_______

(4) safety considerations:

_______

(5) proper disposal and safe handling of flammable free product recovered

♦ static electricity

♦ electrical & instruments per National Electrical Code

IV. SOIL REMEDIATION - GENERAL _______

(1) volume of contaminated soil

_______

(2) recap of Source Removal activities and soil volume already excavated, if any

_______

(3) indication that contaminated soil will be remediated, or provide rationale for 'no action' (4) soil cleanup target levels identified, extent of soil contamination should be delineated by use of both OVA screening results and laboratory analysis results (5) Use of Level I Risk Management Options for soil considered, if applicable, including SPLP, TRPH fractionation, and calculation of site specific SCTLs based on soil properties

_______

(6) proper handling & treatment of excavated, contaminated soil, or proper handling & disposal of hazardous soil (e.g., ignitable, corrosive, reactive, toxic, or petroleum refining waste) V. LAND FARMING OF SOIL

_______

(1) adequate surface area available (______ sq ft) to spread soil 6 to 12 inches thick

_______

(2) location of land farming operation

_______

(3) land farming area is flat (less than 5% slope)

_______

(4) impermeable base provided. Type: _______________________

_______

(5) surface water runoff controls provided

_______

(6) groundwater monitoring plan proposed if land farm is outside of immediate contamination area

_______

(7) frequency of tilling provided

_______

(8) frequency and details of nutrient application or other enhancements provided (if proposed)

_______

(9) soil sampling frequency and sampling methods provided

_______

(10) potential for land farm causing nuisance conditions evaluated (11) underlying soil and groundwater monitoring procedures provided and acceptable

_______

(12) land farming will be continued until the contaminants of concern meet soil cleanup target levels

_______

(13) cost-effectiveness

_______

(14) ultimate disposition of soil discussed

_______

(15) need to fence land farm area considered VI. LANDFILLING OF SOIL

_______

(1) landfill lined and permitted by FDEP

_______

(2) name and location of landfill provided along with conditions of acceptance

_______

(3) cost-effectiveness

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REMEDIAL ACTION PLAN CHECKLIST

Page 4 FAC ID No:___________________________________________

_______

(4) For out-of-state landfill disposal, evidence provided that petroleum contaminated soil disposal in the landfill complies with the landfill regulations of the other state. VII. SOIL THERMAL TREATMENT

_______

(1) name and location of thermal treatment facility provided

_______

(2) facility is permitted for thermal treatment of petroleum contaminated soil

_______

(3) pretreatment soil sample analyses

_______

(4) cost-effectiveness VIII. COMMERCIAL BIOREMEDIATION OF SOIL

_______

(1) name and location of bioremediation facility provided

_______

(2) facility is permitted for bioremediation of petroleum contaminated soil

_______

(3) pretreatment soil sample analyses

_______

(4) cost-effectiveness IX. IN SITU BIOVENTING OF SOIL

_______

(1) soil cleanup criteria identification

_______

(2) estimated mass of contaminants of concern in the vadose zone

_______

(3) recap of information and data from pilot study that is pertinent full-scale system design

_______

(4) layout ♦ well type — vertical or horizontal

♦ well construction details

♦ location of air injection and air extraction wells with respect to contaminated soil plume location and depth ♦ location and depth of soil gas monitoring probes with respect to contaminated soil plume and the air injection and extraction wells _______

(5) design and operating parameters, equipment sizing calculations, mechanical details

_______

(6) instruments, controls, gauges, and valves

_______

(7) monitoring plan: CO2; pertinent bioremediation parameters; contaminants of concern (8) air emissions

_______

♦ demonstration that primary mechanism of remediation will be bioremediation and not volatilization. Air flow rates will be limited based on oxygen demand for bioremediation as demonstrated by pilot study results ♦ evaluation of methods for off-gas treatment if pilot test indicated that a significant amount of hydrocarbon volatilization will occur X. SOIL VAPOR EXTRACTION _______

(1) prerequisites: ♦ relatively permeable soil

_______

(2) recap of information and data from pilot study that is pertinent to full-scale system design: (3) full-scale design

RAP_Checklist_02-03-04.doc

♦ depth to groundwater > 3 ft

♦ relatively volatile contaminants

REMEDIAL ACTION PLAN CHECKLIST

Page 5 FAC ID No:___________________________________________

_______

(a) layout and spacing of SVE wells (consideration given to radius of influence and overlapping of radii)

_______

(b) vapor extraction well(s) ♦ no. of wells ♦ cfm each well ♦ total cfm

♦ well type (vertical or horizontal) ♦ well construction

details _______

( c) pneumatic design ♦ operating vacuum @ wellhead(s) (inches of water) ♦ piping system friction losses ♦ pump motor (hp) based on system losses plus required vacuum at wellhead

_______

(d) vacuum source type: regenerative blower; positive displacement vacuum pump; other ♦ design specifications: cfm @ inches of water; operating cfm @ inches of water ♦ mfr; model; motor hp; rpm; performance curves ♦ nonferrous materials of construction and/or assembly to minimize potential for sparking and friction ♦ explosion-proof motor

_______

(e) moisture separator/condensation trap (“knock out pot”) prior to inlet of vacuum pump

_______

(f)

_______

(g) safety

surface sealing provided for vacuum extraction, or existing concrete or asphalt adequate

♦ system operation at approximately 25% of Lower Explosive Limit (LEL) ♦ bleed valve provided to control flammable vapor concentrations _______

(h) instrumentation, gauges, and appurtenances

_______

(i) air emissions control (general) ♦ method of off-gas treatment to be provided during first month of system operation (provide details in Section X or XI for carbon adsorption or thermal oxidation of off-gas, or provide details of an alternative method)

________

(j) system monitoring ♦ sample and analyze air emissions for total petroleum hydrocarbons, weekly for first month, monthly for next two months, quarterly thereafter ♦ vacuum measurement locations (suggestion: use monitor wells at various radial distances from extraction wells) ♦ acknowledge that air emission controls must be provided for at least first 30 days, but may have to be continued longer until petroleum hydrocarbon emissions to the atmosphere are less than 13.7 lbs/day XI. VAPOR-PHASE CARBON ADSORPTION (for control of air emissions)

_______

(1) recap of information and data from pilot study that is pertinent to full-scale system design, if a pilot was conducted

_______

(2) cost-effectiveness evaluation in comparison to other alternatives for control of air emissions

_______

(3) mechanical details, sizing calculations, and operating parameters

_______

(4) instrumentation, controls, gauges, sampling and valves

_______

(5) safety ♦ operation of system below Lower Explosive Limit (LEL) for type of vapors being handled

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REMEDIAL ACTION PLAN CHECKLIST

Page 6 FAC ID No:___________________________________________

♦ observance of appropriate requirements in Series 500 articles of the National Electrical Code — equipment shall meet either Class I, Group D, Division 1 or Class I, Group D, Division 2 hazardous area requirements, whichever is applicable, when an equipment item is located in a hazardous area as defined by the code XII. THERMAL/CATALYTIC OXIDATION (for control of air emissions) _______

(1) cost-effectiveness evaluation in comparison to other alternatives for control of air emissions

_______

(2) mechanical details, equipment sizing calculations, and operating parameters

_______

(3) instrumentation, controls, gauges, and valves. [schematic or mobile unit manufacturer's drawings indicating instrumentation, controls, gauges, and valves for all process streams (contaminant-laden influent, fuel gas, and combustion air)]

_______

(4) safety considerations include, but are not limited to: ♦ bleed valve or dilution control valve to maintain influent flammable vapor concentration at 25% of the Lower Explosive Limit (LEL) ♦ air purge prior to re-ignition ♦ observance of appropriate requirements in Series 500 articles of the National Electrical Code — equipment shall meet either Class I, Group D, Division 1 or Class I, Group D, Division 2 hazardous area requirements, whichever is applicable, when located in a hazardous area as defined by the code ♦ use of thermal or catalytic oxidizers which meet appropriate fire codes for handling natural or propane gas and prevention of furnace explosions — National Fire Protection Association, Industrial Risk Insurer’s, Factory Mutual, etc. Some of the most important safety shutdowns for gas-fired burners occur upon: high gas pressure; low gas pressure; loss of combustion supply air; loss or failure to establish flame; loss of control system actuating energy; power failure XIII. GROUNDWATER EXTRACTION

_______

(1) feasibility of using existing on-site wells for groundwater extraction considered

_______

(2) recovery well summary ♦ recovery well or trench location(s) and construction details included (diameter, screen length, grout, etc.) ♦ recovery well depth and screen length appropriate for depth of contamination

_______

(3) predicted horizontal and vertical area of influence provided

_______

(4) expected drawdown in recovery well or trench

_______

(5) consideration of multiple well configuration to minimize drawdown

_______

(6) groundwater pump performance requirements, sizing, and description ♦ hydraulic design considerations (friction losses and suction lift) ♦ pump performance curve or information provided (flow rate vs. pressure) ♦ pump manufacturer, model; hp, rpm

_______

(7) automated well level controls provided for stopping/starting groundwater pump(s)

_______

(8) totalizing flowmeter installed on influent line from each groundwater recovery pump

_______

(9) check valve provided on pump discharge piping if not integral to pump

RAP_Checklist_02-03-04.doc

REMEDIAL ACTION PLAN CHECKLIST

Page 7 FAC ID No:___________________________________________

_______

(10) shutoff/throttling valve provided on pump discharge piping XIV. GROUNDWATER TREATMENT SYSTEM - GENERAL

_______

(1) influent concentrations for each contaminant of concern, for design of treatment system, based on either actual dynamic pump test sample, weighted averaging procedure, or other reasonable assumption

_______

(2) feasibility & cost-effectiveness of direct discharge of recovered contaminated groundwater to sewer treatment plant, instead of onsite treatment

_______

(3) site piping summary ♦ schematics of all treatment components, piping, valves, controls and appurtenances provided ♦ influent and effluent sampling ports provided ♦ piping type and size provided

_______

(4) fouling & scaling considerations ♦ whether control of iron fouling is necessary, either by filtration of influent to remove particulately-bound iron, and/or by removal or sequestering of dissolved iron to prevent precipitation in process equipment items ♦ whether pretreatment or other measures necessary to prevent precipitation of calcium carbonate (Langelier Index) ♦ whether pretreatment or scheduled O&M measures will be needed for control of biofouling XV. AIR STRIPPING TREATMENT PROCESS

_______

(1) packed tower ♦ type, size, and surface area of packing ♦ design and operating parameters, sizing calculations, mechanical details (tower height; packing type, height, surface area; air/water ratio; pressure drop; blower type, model, hp; mist eliminator; etc.)

_______

(2) diffused aerator (tank type) ♦ design and operating parameters, sizing calculations, mechanical details (tank volume; contact time; air flow rate; pressure drop; removal efficiency of contaminants of concern; blower type, model, hp; etc.)

_______

(3) low profile air stripper ♦ design and operating parameters, sizing calculations, mechanical details (number of trays; water flow rate; air flow rate; air/water ratio; pressure drop; blower type, model, hp; mist eliminator)

_______

(4) general ♦ instrumentation, controls, gauges and valves ♦ air emissions calculations; emissions stack height ♦ equipment description if emissions treatment necessary ♦ automated recovery well shutdown when blower failure occurs ♦ sampling of effluent, daily for first three days, monthly for next two months, quarterly thereafter XVI. LIQUID-PHASE CARBON ADSORPTION

_______

(1) recap of information and data from pilot study that is pertinent to full-scale system design, if a pilot was conducted

_______

(2) indication whether adsorption is for primary treatment of groundwater or polishing of effluent

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REMEDIAL ACTION PLAN CHECKLIST

Page 8 FAC ID No:___________________________________________

_______

(3) carbon specifications

_______

(4) carbon unit(s) sizing calculations (carbon usage rate, contact time, pressure losses) design assumptions

_______

(5) TOC in groundwater determined and effect on carbon usage considered

_______

(6) need for sand filter or cartridge unit prior to carbon unit considered

_______

(7) pressure gauge and pressure relief valve provided on carbon (and sand) filter

_______

(8) carbon disposal and replacement method

_______

(9) series configuration of carbon units considered to allow for maximum carbon utilization and prevention of contaminant breakthrough to system effluent

_______

(10) automated recovery well shutdown if primary carbon unit pressure too high

_______

(11) schedule for sampling between and after carbon adsorption units XVII. IN SITU AIR SPARGING OF GROUNDWATER

_______

(1) prerequisites ♦ no or little free product which could spread via sparge turbulence, or prolong sparging ♦ volatile (C3-C10) petroleum fractions with Henry’s Constant ≥ 0.00001 atm*m3/mol (approx. rule of thumb, unless biosparging is proposed) ♦ no high concentrations of metals (iron, magnesium) to form oxides which plug aquifer or well screens, or high concentrations of dissolved calcium, which could react with CO2 in air to clog aquifer w/calcium carbonate

_______

(2) recap of information and data from pilot study that is pertinent to full-scale system design (3) full-scale design

_______

(a) groundwater contamination plume coverage ♦ location(s) and radius of influence for full-scale air injection well(s) ♦

_______

adequate coverage by overlapping radii of influence if multiple well system

(b) air injection well(s): no. of wells; well design; operating air pressure at wellheads; cfm each well; total cfm _________________

_______

(c) avoidance of long screen allowing air to diffuse at top portion only, where air flow resistance is least (typ screen is 1 to 3 ft long)

_______

(d) well depth and screened interval (or depth of sparge tip) appropriate w/respect to depth of contamination

_______

(e) vapor extraction well(s) in conjunction w/sparging situated properly to recover volatiles and prevent their release to atmosphere ♦ injection cfm of air typically 20 to 80% of vapor extraction cfm (0.2 to 0.8) ♦ automatic shutdown of air injection upon loss of, or low, vapor extraction system vacuum, or failure of vacuum pump motor, in order to prevent air emissions ♦

_______

adequate and cost-effective treatment of vapor extraction system off-gas proposed to prevent air emissions

(f) compressor ♦ design: cfm @ psig; operating cfm @ psig

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REMEDIAL ACTION PLAN CHECKLIST

Page 9 FAC ID No:___________________________________________



type; mfr; model; motor hp; rpm; performance curves; air filter at compressor inlet; oil trap or oil-free compressor to avoid introducing more contamination to aquifer

_______

(g) safety: pressure relief valve at discharge of compressor and/or high pressure switch for automatic shutdown

_______

(h) instrumentation and gauges: pressure indicating gauges at each sparging well

_______

(i) air flow control: shutoff/throttling valve at each well; other flow control device or method XVIII. IN SITU BIOREMEDIATION

_______

(1) general: ♦ media to be remediated: groundwater; soil ♦ application method: direct-injection; recirculating/re-injection type system; addition to excavation pit ♦ aerobic or anaerobic ♦ stimulation of indigenous microorganisms or addition of microorganisms

_______

(2) recap of information and data from pilot study that is pertinent to full-scale system design

_______

(3) design and operating parameters (e.g.: injection well construction details; layout and spacing of wells commensurate with injection radius of influence for adequate horizontal coverage; screened interval of injection wells commensurate with vertical extent of contamination for adequate vertical coverage; injection pump develops adequate pressure and flow rate for injection , for the site-specific conditions.)

_______

(4) dosage (of nutrients and/or microorganisms, per pound of hydrocarbon contaminants to be biodegraded) ( Some bioremediation products may express dosage as a required amount per cubic yard of contaminated media.)

_______

(5) RAP (or RAP Mod) must contain the necessary underground injection control information required by Chapter 62-528 FAC. [That is, the RAP must contain enough information for a state or local program reviewer to fill out the 2-page UIC notification memorandum titled “Proposed Injection Well(s) for In Situ Aquifer Remediation at a Petroleum Remedial Action Site”.] This includes the following information: ♦ chemical analysis (composition) of the fluid to be injected. Note: The injected fluid must meet primary and secondary drinking water standards of Chapter 62-550, FAC, and the minimum groundwater criteria of Chapters 62-520 and 62-777 FAC, otherwise Rule 62-522.300(2)(c) may apply and/or a zone of discharge variance may be necessary. ♦ no. of injection wells

♦ no. of injection events

♦ injection volume per well per injection event

♦ total injection volume (i.e. the total for all injection wells, all injection events) _______

(7) anticipated schedule of injection events for nutrients and/or microorganisms (i.e. the timing and frequency of injections over the life of the project)

_______

(7) provide additional oxygen, if necessary, if the bioremediation is aerobic and site’s groundwater is lacking in dissolved oxygen. (method by which additional oxygen will be delivered.; provide design details if method of delivery is mechanical, e.g. air sparge, O2 injection, iSOC, etc.; provide chemical information if oxygen is supplied chemically: e.g. magnesium peroxide, calcium peroxide, hydrogen peroxide, etc.)

_______

(9) ♦ sampling plan includes not just the analysis of samples for petroleum contaminants of concern at a site, but also analyses necessary for any of the following that apply: compliance with the underground injection control

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Page 10 FAC ID No:___________________________________________

regulations of Chapter 62-528; compliance with Rule 62-522.300(2)(c); and compliance with the terms of an injection zone of discharge variance. Also, analysis for more than just the reagents may be necessary, depending on the situation. In some cases, if there are environmental or toxicological concerns, it may be necessary to include analysis for intermediate degradation products of the reagents, or intermediate by-products formed by the interaction of those reagents with the petroleum contaminants of concern at a site. ♦ other samples and operating parameter measurements for a bioremediation project may inlcude, but are not necessarily limited to the following: pH, DO, ORP, N, P, Temperature, TOC, Alkalinity., microbe counts XIX. LEAD (this section can also be adapted to other heavy metals if necessary) _______

(1)

discussion of area(s) where groundwater lead concentration exceeds 15 ppb

_______

(2)

lead concentrations (ppb): unfiltered (____); filtered (____); background (____)

_______

(3)

proposal for lead removal by filtration if unfiltered sample is greater than 15 ppb and filtered sample is less

than 15 ppb _______ _______

(4) (5)

method of lead removal, including pertinent design calculations if lead (or other heavy metals) will not be removed by filtration, then provide details of proposed treatment

XX. INFILTRATION GALLERY _______

(1) recap of field percolation test results (preferably with double-ring infiltrometer)

_______

(2) infiltration gallery construction details and location (upgradient location if site layout allows)

_______

(3) gallery calculations/assumptions with mounding analysis

_______

(4) piezometer and cleanout pipe in gallery

_______

(5) geotextile filter fabric to be installed around and above gallery

_______

(6) discussion or modeling of gallery for effect on plume migration XXI. INJECTION WELL (for effluent disposal)

_______

(1) discussion of injection zone and relevant lithology information

_______

(2) recap of information and data from pilot study that is pertinent to full-scale system design, if a pilot was conducted

_______

(3) injection well location and construction details

_______

(4) screened interval appropriate

_______

(5) effluent discharge pump adequately sized for required injection flow rate and pressure

_______

(6) carbon polishing unit (or equivalent)

_______

(6) air release valve at highest point of effluent discharge piping

_______

(7) injection rate (well hydraulics) calculations

_______

(8) Underground Injection Control (UIC) inventory information provided. (RAP or RAP Mod must contain enough information for a technical reviewer to complete the 2-page UIC effluent injection notification.)

_______

(9) evaluation of injection well’s effect on potable wells and plume migration

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Page 11 FAC ID No:___________________________________________

XXII. ALTERNATIVE EFFLUENT DISPOSAL METHODS _______

(1) cost-effectiveness comparison of alternatives (including general permit fee of $2,500 per year in the cost estimate for NPDES disposal, if it is one of the alternatives being compared)

_______

(2) for surface water discharge ♦ conditions for NPDES general permit met ♦ indication that notice of intent for NPDES permit will be submitted after RAP approval

_______

(3) if applicable, consumptive use permit obtained from Water Management District

_______

(4) approval from municipality for sewer discharge, and conditions and effluent standards to be met

_______

(5) applicable permits for stormwater discharge XXIII. SAMPLING REQUIREMENTS

_______

(1) designated / key monitoring wells and frequency of their sampling per 62-770.700, FAC

_______

(2) analysis of designated / key monitoring well samples for appropriate contaminants of concern for the site

_______

(3) sampling of influent from recovery well(s); daily first 3 days, monthly next 2 months, quarterly thereafter

_______

(4) sampling of system effluent, daily for first three days, monthly for next two months, quarterly thereafter

_______

(5) water level data collected at same time & frequency of monitoring well and recovery well sampling XXIV. IN SITU CHEMICAL OXIDATION

_______

(1) media to be remediated: groundwater; soil

_______

(2) recap of information and data from pilot study that is pertinent to full-scale system design

_______

(3) design and operating parameters (e.g.: injection well construction details; layout and spacing of wells commensurate with injection radius of influence for adequate horizontal coverage; screened interval of injection wells commensurate with vertical extent of contamination for adequate vertical coverage; flow rates; temperatures; pressures; pH; concentrations, etc.)

_______

(4) amount of reagents required per pound of hydrocarbons to be destroyed (theoretical amount, actual amount)

_______

(5) RAP (or RAP Mod) must contain the necessary underground injection control information required by Chapter 62-528 FAC. [That is, the RAP must contain enough information for a state or local program reviewer to fill out the 2-page UIC notification memorandum titled “Proposed Injection Well(s) for In Situ Aquifer Remediation at a Petroleum Remedial Action Site”.] This includes the following information: ♦ chemical analysis (composition) of the fluid to be injected. Note: The injected fluid must meet primary and secondary drinking water standards of Chapter 62-550, FAC, and the minimum groundwater criteria of Chapters 62-520 and 62-777 FAC, otherwise Rule 62-522.300(2)(c) may apply and/or a zone of discharge variance may be necessary. ♦ no. of injection wells

♦ no. of injection events

♦ injection volume per well per injection event

♦ total injection volume (i.e. the total for all injection wells, all injection events) _______

(6) ♦ sampling plan includes not just the analysis of samples for petroleum contaminants of concern at a site, but also analyses necessary for any of the following that apply: compliance with the underground injection control regulations of Chapter 62-528; compliance with Rule 62-522.300(2)(c); and compliance with the terms of an

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REMEDIAL ACTION PLAN CHECKLIST

Page 12 FAC ID No:___________________________________________

injection zone of discharge variance. Also, analysis for more than just the reagents may be necessary, depending on the situation. In some cases, if there are environmental or toxicological concerns, it may be necessary to include analysis for intermediate degradation products of the reagents, or intermediate by-products formed by the interaction of those reagents with the petroleum contaminants of concern at a site. ♦ other samples and operating parameter measurements for a chemical oxidation project may inlcude, but are not necessarily limited to the following: pH, DO, ORP, Temperature, and Alkalinity. _______

(7) anticipated schedule of injection events for reagents (i.e. the timing and frequency of injections over the life of the project)

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(8) safety (items applicable to fire, explosion, toxicological and safe handling of chemicals may include, but are not necessarily limited to those listed below) ♦ material safety data sheets, toxicity, or other information pertinent to the chemicals and catalysts involved ♦ safe handling of chemicals: avoidance of mixing, premature mixing, or improper storage of incompatible chemicals ♦ Lower Explosive Level (LEL) considerations ♦ potential for vapor migration, either passively or by convection, or driven by air or other gases used, or generated by the heat of exothermic chemical reactions or the vaporization of free product by such heat ♦ the minimum tolerable distance between underground storage tanks and product piping and any in situ heat-generating process ♦ the need replace the flammable contents of petroleum storage tanks and their associated piping with non-flammable inerts such as nitrogen or carbon dioxide, in order to reduce risk of fire and explosion. ♦ observance of National Electrical Code (typically Series 500 articles for Class I, Group D, Division 1 or 2 hazardous area requirements) (for electrical equipment items located in a hazardous area) ♦ appropriate chemical-resistant and/or spark-resistant materials of construction for equipment items ♦ personal protection of workers ♦ safety considerations regarding neighbors and passersby

RAP_Checklist_02-03-04.doc

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